California 250% Working Disabled Program counts Railroad Retirement disability annuities #10540

California's 250% Working Disabled Program (WDP) exempts disability income from countable unearned income. The Los Angeles County DPSS 250% WDP page exempts "Federal, State and private disability income". Non-Social Security disability income that converts to retirement income at retirement age "is no longer exempt and must be considered unearned income".

The model builds WDP unearned income as ssi_unearned_income minus ca_wdp_disability_income. The exempt list, gov.states.ca.chhs.wdp.eligibility.income.sources.disability, holds social_security_disability, disability_benefits and workers_compensation.

#10534 adds railroad_benefits to the SSI unearned income list, as 42 U.S.C. 1382a(a)(2)(B) requires. WDP therefore now counts every railroad payment, including Railroad Retirement disability annuities. Those annuities convert to age annuities at full retirement age (RRB Quarterly Benefit Statistics, July-September 2025, Table 1, footnote 2), so the county rule exempts them until then. The September 2025 average disability annuity was $3,567.73 a month, or about $42,800 a year. That is above the 2026 California SSI/SSP standard of about $14,807 used by ca_wdp_ssi_ssp_income_eligible, so a working disabled railroad disability annuitant fails that screen.

The railroad_benefits input does not separate disability annuities from age, spouse or survivor annuities. PR 10534 documents this with a NOTE in the exempt-income list.

Options:

• Add a separate input for Railroad Retirement disability annuities and list it among WDP disability income.
• Treat railroad_benefits of a disabled person below full retirement age as disability income for WDP.

Sources:

• https://my.dpss.lacounty.gov/public/en/home/epolicy/program/medi-cal/non-magi/250-percent-wdp.html
• https://stgenssa.sccgov.org/debs/program_handbooks/medi-cal/assets/26250WDP/250WDP.htm
• https://www.rrb.gov/sites/default/files/2026-09/stat_qbs0925.pdf#page=2